MIRANDO V. WELLINGTON TY & BROTHERS., INC.

FACTS:
Petitioners are squatters who originally lived in the premises of Arellano University. However,
through the actions of the Mayor of Manila by virtue of the approval of the Mayor of QC, they
were relocated to the parcels of land now in question which now under the possession of the
Philippine Board of Liquidators (PBL). The Petitioners upon relocation, constructed their homes on
the lots and paid their rentals to PBL. They also filed their applications to the Office of the
President for the sale of the lots to them. However, in 1953, PBL upon the approval of the
President, bartered the lots in dispute for the land of Planas. On 1964, the administrator of Planas
then sold the lots in dispute to private respondents. The respondents, as the new owners then
asked the petitioners to vacate and surrender the possession of the parcels in question and filed
ejectment suits against the latter.
Petitioners, believing that they have preferential rights over the property, filed a petition for
declaratory relief to the CFI. However, the respondents claim that the Petitioners present action
is not the proper remedy and that the petition does not state a sufficient justifiable cause of
action as required by law. The CFI ruled against the petitioners stating that:
The fact that the present petitioners were relocated by the then City Mayor of Manila with
the consent of the City Mayor of Q.C., to the land in question, which was never owned by
either City, did not confer on the petitioners any right over it.
Upon appeal, the CA passed the case to the SC for determination as the issues raised were
purely questions of law.
ISSUE:
Whether the Petitioners remedy of filing a petition for declaratory relief was proper?
HELD:
No. Under the Rules of Court, declaratory relief is an action which any person interested under a
deed, will, contract, or other written instrument, or whose rights are affected by a statute,
executive order or regulation, or ordinance, may, before breach or violation thereof, bring to
determine any question of construction or validity arising under the instrument or statute and for
a declaration of his rights or duties thereunder. In order that an action for declaratory relief may
be entertained, it must be predicated on the following requisite facts or conditions:
(1) there must be a justifiable controversy;
(2) the controversy must be between persons whose interests are adverse;
(3) the party seeking declaratory relief must have a legal interest in the controversy; and
(4) the issue involved must be ripe for judicial determination.
All the requisites in the present case were not present as it is evident from the records that from
the date of their relocation to the disputed lots in 1950 to the date of the filing of this petition for
declaratory relief, at no time did the petitionersappellants acquire any interest whatsoever in the
parcels of land subject of the aforementioned contract of sale. They enjoyed no rights which were
violated, or at the least, affected, by the exchange of properties between the national
government and Planas, and eventually, by the contract of sale to the respondents. Hence the
complaint must, therefore, fail for lack of sufficient cause of action.